As for CSR payments not being made, however, the press release accompanying the rate tables was more vague; it stated that they would be "up to" 14 points higher, but didn't clarify whether that would apply to every individual plan or only the Silver policies, which is how most other states appear to be handling it. I assumed the "no-CSR" average would be roughly 32.9% if the load is only dumped on Silver plans, but 40.7% if spread across all metal levels.
Now that we've passed the 9/27 contract signing deadline for 2018 carrier participation on the ACA exchanges, the state insurance departments are posting their approved final rates pretty quickly. Arkansas has done a fantastic job of clearly laying out not just what the rate changes will be, but is explicitly stating how much of those increases are due to the GOP's refusal to formally appropriate CSR reimbursement payments next year:
Insurance companies offering individual and small group health insurance plans are required to file proposed rates with the Arkansas Insurance Department for review and approval before plans can be sold to consumers. The Department reviews rates to ensure that the plans are priced appropriately. Under Arkansas Law (Ark. Code Ann. § 23-79-110), the Commissioner shall disapprove a rate filing if he/she finds that the rate is not actuarially sound, is excessive, is inadequate, or is unfairly discriminatory. The Department relies on outside actuarial analysis by a member of the American Academy of Actuaries to help determine whether a rate filing is sound.
Insurance Commissioner approves rates insurers filed for 2018; Cost to cover CSRs has been added to silver plan premiums
On September 20, the Tennessee Department of Insurance and Commerce (TDIC) announced that the state had approved the rates that insurers had filed for 2018. However, the announcement indicated that Cigna’s approved average rate increase was 42.1 percent, which was based on the filing Cigna submitted in June 2017. An updated filing, with an average rate increase of 36.5 percent, was submitted in August, and TDIC confirmed by phone on September 21 that the updated filing was approved. The slightly smaller rate increase is due to Cigna’s decision to terminate some existing plans and replace them with new plans).
The following average rate increases were approved for 2018 individual market coverage:
In August I wrote that the situation in North Dakota was pretty straightforward: Three carriers on the individual exchange (BCBS, Medica and Sanford), requesting average rate hikes of around 24%, 19% and 12% respectively for an average increase of 23% assuming CSR payments are made, or a bit higher (28%) if they aren't.
Medica understandably refused to take that risk (the odds of CSRs being guaranteed are virtually nil, and the odds of them being paid each and every month, as they're supposed to, is only so-so), so they dropped out instead.
Back in August, I reported that thanks to their just-approved federal reinsurance program, Alaska (which has only a single individual market carrier with the most expensive premiums in the country) is looking at an impressive 22% average decrease in their indy market premiums next year. However, that was based on the assumption that CSR reimbursement payments would not be made (or at least not guaranteed).
INSURANCE DEPARTMENT RELEASES PROPOSED RATES FOR 2018 HEALTHCARE EXCHANGE
Atlanta – Insurance Commissioner Ralph Hudgens announced today that his office had submitted proposed 2018 health insurance rates to the Centers for Medicare and Medicaid Services (CMS) for the federally-facilitated Healthcare Exchange for final federal approval.
“Today my office submitted 2018 Obamacare rates to Washington D.C. for approval,” Hudgens said. “In its fifth year, Obamacare has become even more unaffordable for Georgia’s middle class with potential premium increases up to 57.5 percent. I am disappointed by reports that the latest Obamacare repeal has stalled once again and urge Congress to take action to end this failed health insurance experiment.”
Anthem leaving Maine ACA marketplace, citing uncertainty
Anthem Blue Cross Blue Shield has withdrawn nearly all of its offerings from Maine’s Affordable Care Act health insurance marketplace, and the insurer is citing market uncertainty and volatility as the reasons.
I've spent the past two weeks posting about almost nothing besides the Graham-Cassidy debacle, so haven't had a chance to keep on top of the approved 2018 rate changes as I usually do. Fortunately, Louise Norris of healthinsurance.org has stayed on the rate hike job, and reports the final numbers out of Washington State:
2018 rates: 24% approved rate increase, due in large part to federal uncertainty — and higher backup rates will be implemented if CSR funding is cut mid-year
Insurers in Washington had to file rates and plans for 2018 by June 7, 2017. On June 8, Kreidler’s office published a summary of what had been filed (rate filings are available here, and that page will show final rate changes for the individual market once they’re approved), and publicized the filing details on June 19. The average proposed rate increase in Washington, before any subsidies are applied, was 22.3 percent.
Back in August it looked as though Florida carriers were looking at either 15.5% unsubsidized rate increases on the individual market if CSR reimbursement payments were guaranteed next year, or around 35.5% if they weren't. Well, the official rates have been released by the Florida Dept. of Insurance, and it's even uglier than that for unsubsidized enrollees:
Office Announces Submission of Proposed Rates for 2018 Federal PPACA Health Insurance Plans
(sigh) When I last checked in on Virginia, things were looking up a bit (relatively speaking), as Anthem Blue Cross Blue Shield (aka "HealthKeepers") had announced that they were jumping back into the state in order to cover the 60-odd counties which would otherwise be left bare by Optima Health Insurance dropping out of half the state a week or so earlier.
Regular readers know that one of the issues I've spent the better part of the past year yammering on about endlessly is the importance of Congress formally appropriating Cost Sharing Reduction reimbursement payments to the insurance carriers on the individual market exchanges.
Thanks to the ongoing/pending ruling in the federal House vs. Burwell Price lawsuit, Donald Trump has the ability to pull the plug on CSR payments pretty much whenever he wants to (and he's threatened to cut them off every month since around March or April so far). CSR payments hang like a Sword of Damocles over the heads of every exchange-based insurance carrier each month, with them never knowing whether they'll get reimbursed or not.
Louisiana was one of the last states I ran rate hike analysis on just a month ago: Three carriers on the exchange (plus the "Freedom Life" phantom carrier), averaging around 21.4% rate increases on the assumption that CSR payments won't be made. According to the Kaiser Family Foundation, loading CSRs onto Silver plans only would bump them up by an additional 20 points; this translates into roughly 14.2 points if spread across all metal levels on & off the exchange. Based on that, I estimated LA's rate increases at 21.4% without CSRs but only 7.2% if they actually are paid.
I've written not one, not two, but three different blog entries in the past 24 hours about Bernie Sanders' just-announced "Medicare for All" proposal...but the reality is, I shouldn't have. Frankly, while it's a discussion/debate that we do need to have, making a big thing about it right this moment is, the more I think about it, terrible timing, because the Affordable Care Act is still in being attacked and at risk in several ways:
FIRST: The CSR issue still hasn't been resolved, although at this point it's extremely unlikely that Patty Murray and Lamar Alexander are going to pull a CSR/reinsurance rabbit out of their hats after all. Last week things looked somewhat promising, but this week it appears to have gone off the rails again...and with just 17 days left in the fiscal year (and, I believe, only 14 days before the contracts have to be signed by carriers for 2018 exchange participation), there's almost no time left to get even a minor stabilization bill pushed through.
SECOND: On a related note, Bill "so much for the Jimmy Kimmel test!" Cassidy and Lindsey Graham are still trying to cram through their pile-of-garbage Hal Mary Trumpcare bill, which is at least as bad as the GOP's failed AHCA/BCRAP bills were earlier this year and even worse in some ways. Again, there's only 17 days left to pull it off, but remember what happened with AHCA last spring...anything's possible. Here's a summary of the impact of the Cassidy-Graham bill via Andy Slavitt and the Centers for Budget & Policy: